ZETA BUILDTECH PRIVATE LIMITED,DELHI vs. DEPUTY COMMISSIONER OF INCOME TAX, CENTRAL CIRCLE-7, DELHI, DELHI

ITA 3449/DEL/2025Status: DisposedITAT Delhi12 February 2026AY 2020-21Bench: SHRI S. RIFAUR RAHMAN (Accountant Member), SHRI RAJ KUMAR CHAUHAN (Judicial Member)8 pages
AI SummaryAllowed

What did the Tribunal hold?

The Tribunal held that payments made to unrelated and independent parties for business purposes cannot be disallowed on grounds of being excessive or unreasonable, especially when the books of account were not rejected. The Tribunal found that the assessee had provided sufficient documentation and that the nature of the services required independent agencies.

What were the facts?

The assessee claimed expenses for internal checks, MIS reports, and marketing services provided by unrelated third parties. The Assessing Officer disallowed a portion of these expenses, deeming them excessive or unsubstantiated. The CIT(A) upheld these disallowances.

What were the issues?

Whether expenses paid to unrelated parties for business purposes can be disallowed on the grounds of being excessive or unreasonable without rejecting the books of account. Whether the assessee substantiated the expenses claimed for internal checks, MIS reports, and marketing services.

Which sections of the Income-tax Act were involved?

Section 145(3)

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Income Tax Appellate Tribunal, DELHI BENCHES ‘E’: NEW DELHI.

Before: SHRI S. RIFAUR RAHMAN & SHRI RAJ KUMAR CHAUHAN

For Respondent: Ms. Ankush Kalra, Sr.DR
Hearing: 09.12.2025

PER S. RIFAUR RAHMAN, ACCOUNTANT MEMBER :

1.

This appeal is filed by the assessee against the order of Ld. Commissioner of Income Tax (Appeals)-24, New Delhi (hereinafter referred to ‘ld. CIT(A)’) dated 30.12.2024 for AY 2020-21. 2. At the time of filing of appeal, the Registry has pointed out a defect that appeal is time barred by 87 days.

3.

We have heard both the counsels on the issue of condonation of delay. In our considered opinion, there was a reasonable cause for the delay in 2 filing the appeal. Therefore, we condone the delay in filing the appeal before the Tribunal.

4.

Brief facts of the case are, assessee filed its return of income for Assessment Year 2020-21 on 08.01.2021 declaring total income

The order continues below.

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